Perry Ponder, who first brought the 1969 DOT discussion of side underride protection to my attention in 2016 and has invented the AngelWing side guard, recently submitted another Public Comment to NHTSA. He addresses industry concerns about side guards — providing thorough documentation.

An excerpt of Ponder’s 2020 comments: Continuing to allow truck and trailer induced PCI in rear and side underride crashes to occur at otherwise survivable crash speeds (delta-V’s of 45mph and beyond) discards years of crashworthiness efforts and wastes the safety benefits we have come to expect and pay for in our cars.

From an engineering perspective the need for vehicle crash compatibility in the form of adequate heavy truck underride guarding is apparent in order to protect against the hazard of PCI which exposes the vulnerable head and neck region to severe, potentially fatal or crippling injury. This hazard is easily remedied by readily available materials and simple structural analysis. Read more here.

Here is Perry’s 2016 Public Comment in which he asked for NHTSA to extend underride protection to the sides of trucks and mentioned that it was the original intent of the underride rulemaking in 1969. This is what the Federal Highway Administration said at that time,

It is anticipated that the proposed standard will be amended, after technical studies have been completed, to extend the requirement for underride protection to the sides of large vehicles.

Imagine! In 1969.

Here is that 1969 document:

This was the original intent of NHTSA rulemakers in the 1969 NPRM, Docket No. 1-11; Notice 2.